Keywords: GDPR, CASL, Consent, forgotten, erasure,
The Right to be Forgotten is how Article 17 - Right to Erasure is often referred to. It is one of several fundamental rights of a data subject based in the EU, under the EU GDPR which comes into force 25 May 2018.
The law says that the data controller must erase personal data, without undue delay, if the data subject withdraws the consent on which the processing is based, or if other circumstances apply. The erasure must happen as long as no exemptions apply, such as needing to retain the data because of Public Interest, or a Legal Obligation, or in defence of Legal Claims, or some others. The full text of Article 17 is available online.
This means that if you receive a request to be forgotten from one of your clients you should (unless an overriding exemption applies), without delay, remove their personal data from your systems and inform Vuture, who will do the same.
Vuture will manually delete the individual from everywhere they appear in our systems.
To request a contact be forgotten by Vuture, go to Help in your Vx platform and then select Healthchecks from the drop down menu. Click the link for the GDPR Healthcheck. There is a section in this Healthcheck (Section 8) which outlines the Right to be Forgotten. Contained in this section is an area you can click which will generate an email to our Support team. Fill in the details of the contact who has made the request to be forgotten. This will then be actioned by our technical team and the contact's data will be removed.
Since deleting contacts will affect your historical reporting, instead of deleting we will switch the name to Deleted and the email to Deleted. Your numbers will still match but the individual in question will have been removed.
There is an article here which discusses the Data Retention policy at Vuture.